Modern SlaveryReporting Requirements

Preventing Imports Produced under Modern Slavery Conditions

If you're an Australian business with over A$100M in annual group revenue, there are strict Modern Slavery Reporting Requirements you must adhere to.

To ensure compliance with the Australian Government's Modern Slavery Act 2018, you must submit an annual modern slavery statement reporting on risks in your company's supply chain. You are required to upload it to a public register - modernslaveryregister.gov.au

As such, the onus is on you as a business owner or importer to minimise the risk of modern slavery in your supply chains.

Penalties for failing to do so are currently being explored to be added to the Act. ACCC action for 'greenwashing' is also becoming common place with a huge task force now in place.

As Australia's first wholesale customs clearance service to have been awarded Australian Trusted Trader status since 2017, 3DL Customs & Consulting have engaged with experts in this field. Our experienced customs consultants and legal practitioners can assist you with your reporting to ensure you're fully compliant and engaging in ethical and socially responsible business practices.

What is Modern Slavery?

Modern slavery describes any situation where offenders use coercion, threats or deception to exploit victims and undermine their freedom. It includes practices such as forced labour, child labour, human trafficking, slavery, servitude, and debt bondage.

What is the Aim of the Modern Slavery Reporting Requirements?

Through improving business awareness and transparency of modern slavery, the legislation aims to reduce modern slavery risks in the production and supply chains of Australian goods and services. It is also aimed at helping improve workplace practices and human rights on a global scale.

How Can I Be Sure my Goods Haven't Been Produced Under Modern Slavery Conditions?

We strongly recommend that you engage our partners to help you assess where the problems might be in your supply chain by conducting a preliminary audit of your production supply chain prior to purchasing your goods. It is also imperative to do a modern slavery risk assessment of your supplier and manufacturer to rule out any potential association based on international known factors.

At 3DL Customs & Consulting, our expert legal practitioner partners are highly experienced in conducting these risk assessments and can give you full peace of mind that you are 100% compliant and conducting ethical business.

What Are My Modern Slavery Reporting Requirements?

In Australia, the only legal requirement currently is to report on the risk of modern slavery in your international supply chains. Even companies that are not legally required to conduct modern slavery risk assessments may volunteer to assess and report their compliance - and there are benefits to doing so. Alternatively, they may be asked for information from large company end users of their products.

While the importation of such products to Australia is not yet banned, in May 2023 a review was tabled in parliament which included recommendations of stricter guidelines and penalties for non-compliance. These range from introducing due diligence obligations and civil penalties and enabling the seizure of goods at the port reportedly produced in slavery conditions. Further, it has been recommended that the consolidated revenue threshold be lowered from $100 million to $50 million.

This will be complex territory because importers may be required to trace and prove all raw materials in their products (such as thread in clothing, or individual ingredients in processed foods) were not produced under modern slavery conditions. Stringent penalties are likely to apply for non-compliance, and affected imports could be detained and destroyed.

Your Partner in Regulatory and Corporate Social Responsibility

Fortunately, when you engage 3DL Customs & Consulting to manage your Modern Slavery Reporting Requirements, you can rest assured we're on top of legislative changes as they happen, and we have collaborated with a specialist law firm, to provide you with the highest quality and most up to date guidance on meeting your legal and social accountability obligations.

Our highly skilled customs brokers possess on average 28 years' industry experience. With the assistance of our collaborators, we can assist you with preparing and submitting your statement, giving you peace of mind that you are fully compliant, and your goods are cleared through customs quickly and efficiently.

If you're after expert guidance and advice on how to fulfil your Modern Slavery Reporting Requirements, contact us today on (07) 3268 1797.

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